Much has been written about the science of genetically-modified (GM) or genetically-engineered (GE) crops, as well as the role of these crops in global food production. Scientists, regulators and many agricultural groups have continually reinforced the position that GE foods are safe and are not substantially different than non-GE foods. But recent months have brought increased calls for mandatory labeling from consumer interest groups, as well as environmental and small farm groups.
California voters defeated a 2012 ballot initiative that would have required labeling of GE food, but similar initiatives are pending in other states, including one in Oregon. Moreover, California and Oregon legislators have just introduced legislation in Congress that would mandate GE labeling nationwide. Is a mandatory GE label in the public interest? Does it provide health, nutrient or even social information to consumers who are demanding more information? Or, would a label stigmatize GE food products and reduce consumer demand and acceptance, even when there are no scientifically-established differences between GE and non-GE food products?
There are essentially four policy alternatives available to address GE labeling or more generally, any food labeling question:
- Mandatory labeling.
- Voluntary labeling with regulated and standardized label information.
- Voluntary labeling with no standardized label information.
- Prohibition on labeling.
A USDA Economic Research Service (ERS) report by Elise Golan, et al., provides a timely reference point for these labeling alternatives, which is impressive given it was published in 2000 (http://www.ers.usda.gov/media/532216/aer793.pdf).
Consider the mandatory labeling alternative as is currently being pushed on many fronts. Nutrition labels have been required for a long time to clarify for consumers the nutritional content of a product and to help consumers choose a healthier diet. Mandatory country-of-origin labeling (COOL) is back in the news as USDA is revising rules in response to trade conflicts over existing World Trade Organization rules.
The role of mandatory food labeling is to provide consumers with useful product information that may not be provided without the mandatory requirement. Nutritional information is targeted at the social objective of improving our diets and health—presuming we choose to follow the guidance. Varied interest groups have pushed mandatory COOL as responding to consumer preferences, as well as the consumer’s “right to know.” A similar argument is being made for mandatory GE labels, i.e. that labels could provide information that may benefit consumers. But labels would also come with added labeling/tracking/production costs. Labels may also implicitly stigmatize GE food products in the eyes of consumers and reduce acceptance, regardless of underlying science or safety—no doubt a goal of some interest groups though an outcome that doesn’t seem to be in the public interest.
Voluntary labeling is the obvious alternative that allows entrepreneurial producers and manufacturers to respond to whatever consumer interest or demand exists. The shelves at the grocery store are lined with labeled food products touting the manufacturer’s message and the product’s attributes, all geared to attracting the consumer and making a sale. The labeling choice, which balances labeling/tracking/production costs and consumer demand, is analyzed and determined in the market with relatively little government intervention or regulatory cost. Numerous products and attributes currently show up through this open, voluntary marketing and labeling route, including welfare-friendly, family-farm-raised and even the non-GE food products of the current debate.
When the plethora of privately-developed voluntary labels becomes a confusing maze for consumers, there may be a role for public intervention to define standards and terms for the label. This is the third alternative—a regulated and standardized voluntary labeling regime. Organic production and labeling fits this category. As the organic production sector developed in the United States over the past half-century and consumer interest grew, private-sector organizations began to develop certification standards in the 1970s to both support the sector and prevent fraud in organic claims marketed to consumers. With numerous certification organizations and inherent differences in standards between organizations, there was obvious conflict over the exact definition of organic, as well as confusion for the consumer. In response, the Organic Foods Production Act of 1990 was introduced to create a national standard and certification program for organic production and labeling.
A fourth alternative policy choice is to prohibit labeling—an alternative that is presumably limited to instances where there is no scientific distinction to be made in the food product and where labeling could provide misinformation. While not a labeling prohibition per se, the requirement that non-BST (bovine somatotropin) milk labels contain a clause that says there is no scientific difference between BST and non-BST milk strives to avoid consumer confusion about BST and reduce or eliminate any potential stigma implied by the non-BST label.
With the widespread adoption and general acceptance of GE crops in the United States, it can be difficult to understand the current push for mandatory labeling provisions. But if labeling proceeds, there are four basic labeling regimes to be considered. With voluntary labeling already in the market, the case will have to be made as to why any shift to mandatory labeling should be considered.